GR 133813; (August, 2004) (Digest)
G.R. No. 133813 ; August 11, 2004
SALVADOR ANDALIS y MORALLO, petitioner, vs. COURT OF APPEALS, REGIONAL TRIAL COURT OF CAMARINES SUR, BRANCH XXXV, and THE PEOPLE OF THE PHILIPPINES, respondents.
FACTS
On December 25, 1992, in San Agustin, Iriga City, a drinking session among several individuals, including petitioner Salvador Andalis and the victim Pio Gonowon, took place. The prosecution’s evidence, primarily through eyewitness Alex Embestro, established that during the session, an argument ensued between Andalis and Gonowon. Andalis, irritated, hit Gonowon with a chair. As Gonowon fled, Andalis chased him and stabbed him three times in the back with a fan knife, causing his death. Another witness, Justo Retrita, corroborated the stabbing incident.
The defense presented a different narrative. Andalis, through his wife Vivian, claimed he acted in defense of his wife’s honor. He testified that he left the drinking session and went home, where he found a very drunk Gonowon inside his house, allegedly attempting to molest Vivian. Andalis asserted that he stabbed Gonowon to stop this unlawful aggression.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s conviction of the petitioner for Homicide, thereby rejecting his claim of justifying circumstance of defense of relative’s honor.
RULING
The Supreme Court denied the petition and affirmed the conviction. The Court upheld the factual findings of the lower courts, which gave greater weight to the prosecution’s version of events. The legal logic centered on the requisites for justifying circumstances, particularly defense of a relative. For such defense to be valid, there must be unlawful aggression on the part of the victim. The trial court found the defense’s story inherently improbable and insufficient to prove such aggression.
The Court noted the significant consumption of alcohol by the group, casting doubt on the physical capacity of a severely intoxicated Gonowon to commit the alleged molestation. Medical science indicates alcohol is a depressant, suppressing libido. Furthermore, Vivian Andalis admitted she had never noticed any prior amorous inclination from Gonowon and had left the house early that Christmas morning, making it unlikely Gonowon knew she was home to target her. The claim of unlawful aggression was therefore unsubstantiated. The positive, consistent, and credible testimonies of the prosecution eyewitnesses, who had no motive to falsely testify, prevailed over the petitioner’s self-serving claim. The elements of Homicide—that the petitioner killed the victim without any justifying circumstance—were thus proven beyond reasonable doubt.